Georgia Supreme Court Censures D.A.'s Office for AI-Generated False Case Citations in Murder Appeal

The Georgia Supreme Court issued a scathing order last week admonishing the Clayton County District Attorney’s office for its role in filing briefs and court orders containing 21 AI-generated case citations that were never independently verified. The decision stems from the appeal of Hannah Payne, who was sentenced to life in prison plus 13 years for the murder and false imprisonment of Kenneth Herring and firearm possession during a felony.

Court Finds Widespread AI Hallucinations in Prosecutorial Filings

In Payne v. State, decided on March 20, 2025, Justice Benjamin Land wrote that Assistant District Attorney Deborah Leslie filed multiple documents—including Payne’s motion for a new trial and the trial court’s order denying it—containing non-existent or misattributed case citations. These errors were later traced to artificial intelligence software used without verification.

The court stated:

"As a result of these filings, we have been sidetracked from our obligation of resolving the merits of Payne’s appeal and have had to devote significant time and resources to the discovery of this misconduct and deciding what to do about it."

ADA Leslie Admits AI Reliance Without Verification

On appeal, ADA Leslie acknowledged that the fictitious citations were generated by AI software and included in briefs and proposed orders without independent verification. She claimed to have implemented safeguards to prevent future errors. However, the court identified nine AI-generated cases in its March 20, 2025, order and twelve additional cases in Leslie’s trial court filings that were similarly unverified.

Court Imposes Sanctions and Orders Remand

The Georgia Supreme Court took the following actions:

• Admonished ADA Leslie and the Clayton County District Attorney’s Office for failing to verify case citations.
• Suspended ADA Leslie’s privilege to practice in the court.
• Vacated the trial court’s order denying Payne’s motion for a new trial.
• Remanded the case to the trial court with instructions to issue a new order free of fake or misattributed citations.

The court cited Supreme Court Rule 7, which requires parties and counsel to ensure filings are truthful and accurate. It noted that the district attorney’s office had already issued a March 27, 2026, letter apologizing for the post-trial filings and announcing new AI-use policies, including disciplinary action against Leslie.

Dissenting Opinion Cites Office’s Remorse

The court’s order acknowledged the district attorney’s apology and corrective measures but emphasized that the misconduct had already caused substantial delay and resource diversion. The dissenting opinion reportedly relied on the office’s remorse in arguing for a less severe penalty, though the majority imposed firm sanctions.